MEMORANDUM OPINION
GALE, Judge:
Respondent made the following determinations with respect to petitioner's 1993 and 1994 Federal income taxes:
Addition to Tax Penalty Year Deficiency Sec. 6651(a) Sec. 6662 1993 ...... $16,649 -- $3,330 1994 ...... 8,820 $2,205 ...
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